Kim v. Coach, Inc, et al

Filing 52

NOTICE of Compliance With May 4, 2011 Order by Defendants Coach Services Inc, Coach, Inc.. (Attachments: # 1 Response to Motion to Strike, # 2 Dec of Macaluso, # 3 Motion to Strike Class Allegations, # 4 Proposed Order Granting Motion to Strike, # 5 Dec of Axilrod, # 6 Dec of Macaluso, # 7 Reply in Support of Motion to Strike, for Sanctions, # 8 Appendix 1 to Reply, # 9 Appendix 2 to Reply)(Keehnel, Stellman)

THE HONORABLE RICARDO S. MARTINEZ

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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GINA KIM, on behalf of a class consisting
of herself and all other persons similarly
situated,

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Plaintiffs, and as to Ms.
Kim, counterclaim
defendant,

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NO. 2:11-cv-00214-RSM
DEFENDANTS’ NOTICE OF
COMPLIANCE WITH MAY 4, 2011
ORDER

v.
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COACH, INC., a Maryland corporation,
and COACH SERVICES, INC., a
Maryland corporation,

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Defendants, and, as to
Coach, Inc., counterclaim
plaintiff.

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In compliance with the Court's May 4, 2011 Order (Dkt. No. 49), Coach, Inc. and

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Coach Services, Inc. (together, “Coach”) hereby submit the following redacted versions of

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documents previously filed under seal:

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1.

Coach, Inc.’s Opposition to Special Motion to Strike and for Sanctions, filed

March 28, 2011, Dkt. 24. This document in redacted form was previously filed as Dkt. No. 38.
2.

Declaration of John Macaluso in Support of Defendant Coach, Inc.’s Opposition

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to Special Motion to Strike, with attached Exhibits A-E, filed March 28, 2011, Dkt. 25. This

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document in redacted form was previously filed as Dkt. No. 39.
DEFENDANTS’ NOTICE OF COMPLIANCE
WITH MAY 4, 2011 ORDER - 1
NO. 2:11-cv-00214-RSM

DLA Piper LLP (US)
701 Fifth Avenue, Suite 7000
Seattle, WA 98104-7044 | Tel: [phone]

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Granting Defendants’ Motion to Strike Class Allegations, filed April 14, 2011, Dkt. 42.
4.

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Declaration of Nancy Axilrod in Support of Defendants’ Motion to Strike Class

Allegations, filed April 14, 2011, Dkt. 43.
5.

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Defendants’ Motion to Strike Class Allegations, with attached [Proposed] Order

Declaration of John Macaluso in Support of Defendants’ Motion to Strike Class

Allegations with attached Exhibits A, N, O-Q, filed April 14, 2011, Dkt. 44.
6.

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Plaintiffs’ Reply in Support of Motion to Strike and for Sanctions Pursuant to

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Washington’s Anti-SLAPP Statute, RCW 4.24.525, Dkt. No. 31. Although this document and

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motion to seal were filed by plaintiffs, the Court’s May 4, 2011 order requires Coach to file a

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redacted copy of the brief. (Dkt. No. 49.) Plaintiffs indicated in their motion to seal (Dkt. No.

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32) that they filed this document under seal in an effort to avoid disclosing any of Coach, Inc.’s

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confidential information. This brief does not contain any confidential information. In

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compliance with the Court’s May 4, 2011 order, Coach therefore attaches the entire, unredacted

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brief.

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Respectfully submitted this 11th day of May, 2011.
DLA Piper LLP (US)

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By: s/ Stellman Keehnel
Stellman Keehnel, WSBA No. 9309
R. Omar Riojas, WSBA No. 35400
Patrick Eagan, WSBA No. 42679
DLA Piper LLP (US)
701 Fifth Avenue, Suite 7000
Seattle, WA 98104
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]
Attorneys for defendant and counterclaim plaintiff
Coach, Inc. and defendant Coach Services, Inc.

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DEFENDANTS’ NOTICE OF COMPLIANCE
WITH MAY 4, 2011 ORDER - 2
NO. 2:11-cv-00214-RSM

DLA Piper LLP (US)
701 Fifth Avenue, Suite 7000
Seattle, WA 98104-7044 | Tel: [phone]

CERTIFICATE OF SERVICE

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I hereby certify that on May 11, 2011, I caused to be electronically filed the foregoing

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with the Clerk of the Court using the CM/ECF system which will send notification of such

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filing to all counsel of record.

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Dated this 11th day of May, 2011.

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s/ Stellman Keehnel
Stellman Keehnel, WSBA No. 9309

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WEST\223448950.1

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DEFENDANTS’ NOTICE OF COMPLIANCE
WITH MAY 4, 2011 ORDER - 3
NO. 2:11-cv-00214-RSM

DLA Piper LLP (US)
701 Fifth Avenue, Suite 7000
Seattle, WA 98104-7044 | Tel: [phone]